Approach to Compliance

1. Setting a Compliance Committee

Shindengen Group considers compliance with laws and regulations such as Competition Laws and Bribery Prevention Laws as one of its top priorities. Establishment and timely improvement of effective compliance management procedures and standards is essential. Regular compliance training, as well as keeping up to date with the latest laws and regulations ensures Shindengen can meet its compliance obligations. On October 1, 2015, a Compliance Committee was established with Shindengen’s President as the Chair, and it aims to support the establishment, implementation, and improvement of compliance management at domestic and overseas sites.

•Revised Shindengen Group Guideline for Action

In April 2016, we renewed “Shindengen Group Guideline for Action”to add in terms of observance of competition laws and bribery regulations. We sent this revised guideline to all employees of Shindengen Group companies under the name of the chairperson and updated the website with it.
In FY 2017, overseas Group companies translated these action guidelines into the local languages of each country, and are thoroughly informed and educated.

Competition Law

In FY 2016, the working team of the Compliance Committee took the initiative to establish internal rules and emergency response manuals to obey the relevant laws.
In FY 2017, the Compliance Committee Secretariat supported the establishment of compliance programs at overseas group companies, and the development of regulations, etc. for each group company. The subject activities were almost completed.
While implementing competition law education and training on an ongoing basis, in FY 2017, the Secretariat focused on business combination and conducted in-house training on staff divisions and sales departments concerning notes on pre-notification systems, etc. to authorities.

•Bribery Prevention Actions

In FY 2016, as with the competition law, the working team set up anti-bribery provisions, operational manuals, etc.
In FY 2017, we implemented the same support as for the competition law, and the classifications, etc. of overseas group companies were upgraded. We also conducted in-house training on bribery regulation in the US, UK, and China for the sales department.

•Initiatives for the Personal Information Protection Law

With the enforcement of Japan’s revised Personal Information Protection Law, we created a new working team, mapped personal data, developed regulations, etc.
Based on the enforcement of the EU General Data Protection Rule (GDPR), the Secretariat and the European subsidiary (Shindengen UK) are working together to grasp the contents of laws, regulations, and guidelines while seeking advice from experts, and have implemented practical measures such as data mapping of Shindengen UK.
In January 2018, we invited experts on education and training on the Personal Information Protection Law, including the GDPR, for board members and department managers.

in-house Training on the Personal Information Protection Law

2.Whistleblowing System and Internal Reporting on Corporate Compliance

To ensure Shindengen Group operates to the highest legal and ethical standards, an internal whistle-blowing system has been established. This aims to provide a safe communication channel for employees to report and respond appropriately to illegal and/or unethical conduct. A whistleblower hotline was established which is responded by the internal audit department, and/or an external lawyer. The communication channels are available to domestic group companies. Overseas subsidiaries have similar safe communication channels, and report periodically to head office management.

3. Compliance with the Subcontract Act

Shindengen Group considers compliance with the Subcontract Proceeds Payment Delay Prevention Laws (Subcontract Act), a special Law under the Anti-Monopoly Laws, essential for the promotion of fair trade. Shindengen’s Materials Division is responsible for regular education training sessions, preventative actions, and on-site compliance inspections for all group companies.

4. Anti-Social Forces

Shindengen is committed to fulfilling its social responsibilities, by not engaging with any group or individual that endangers or harms society. Any group or individual that endangers or harms society identified internally, or with business partners is ceased immediately. Therefore, we kindly ask our stakeholders to sign the “Memorandum of the Anti-social Forces”.